Adam Frankel
General Counsel · Technology & AI
15+ years as General Counsel to technology, cloud & AI companies
SIAC Rules (2025, 7th Edition) — Statement of Defence
Archetype: Memorial
This document is prepared under the SIAC Rules (2025, 7th Edition), effective 1 January 2025. The Memorial archetype sets out full legal argument and evidence inline; contrast the Pleading archetype, which pleads material facts only.
This template numbers every paragraph, including optional ones, as though included. Delete any paragraph or clause that does not apply to this filing and renumber sequentially before submission.
Preliminary Matters
Include the following paragraph only if the Respondent elects, pursuant to Rule 7.2 of the SIAC Rules (2025, 7th Edition), to include its Statement of Defence (and Statement of Counterclaim, if any) in its Response to the Notice of Arbitration:
The Respondent elects to include its Statement of Defence in its Response to the Notice of Arbitration. This election is optional for the Respondent under Rule 7.2, in contrast to the Claimant's position under Rule 6.4, where the equivalent election is mandatory if made.
This arbitration may proceed under the Streamlined Procedure or the Expedited Procedure. If either applies, confirm the applicable timetable with the Registrar or Tribunal before filing this Statement of Defence.
Jurisdiction Gate — Time-Bar Warning. Any jurisdictional objection is governed by Rule 31.2(a) of the SIAC Rules (2025, 7th Edition), which is dual-limbed: an objection that the Tribunal does not have jurisdiction must be raised no later than in a Statement of Defence or, with respect to a counterclaim, in a Statement of Defence to a Counterclaim. Confirm which limb applies to this Respondent's position before filing. A party may also flag an objection earlier, in the Response, per Rule 7.1(d) — this is optional and does not itself set the time-bar.
STATEMENT OF DEFENCE
Where a counterclaim is pleaded within this document (see Section 13 below), the title should read "STATEMENT OF DEFENCE AND STATEMENT OF COUNTERCLAIM."
SIAC Case No.: [Insert case number, if assigned]
IN THE MATTER OF AN ARBITRATION UNDER THE SIAC RULES (2025, 7th EDITION)
BETWEEN
[Claimant's name] of [Claimant's address] ("Claimant")
— and —
[Respondent's name] of [Respondent's address] ("Respondent")
Submitted on behalf of the Respondent by: [Representative's title] [Representative's name]
Date: [Date]
Introduction
This Statement of Defence is submitted pursuant to Rule 33.3, in reply to the particulars of the Statement of Claim.
Section index: (I) Third-Party Funding Disclosure; (II) the Parties; (III) Jurisdiction; (IV) General Traverse; (V) Paragraph-by-Paragraph Reply; (VI) Factual Background; (VII) Legal Grounds; (VIII) Affirmative Defences; (IX) Quantum Response; (X) Statement of Counterclaim, if pleaded; (XI) Relief Sought; (XII) Annexure Schedule.
Third-Party Funding Disclosure
Pursuant to Rule 38.1 of the SIAC Rules (2025, 7th Edition), the Respondent discloses that no third-party funding agreement exists as at the date of this Statement of Defence.
Where a third-party funding agreement exists, substitute the following for paragraph 3: Pursuant to Rule 38.1 of the SIAC Rules (2025, 7th Edition), the Respondent discloses the existence of a third-party funding agreement. The identity and contact details of the funder are [funder details].
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About this template
What is this template?
This is a formal legal filing used to respond to a Statement of Claim in an arbitration administered by the Singapore International Arbitration Centre. It is a 'Memorial' archetype, meaning it contains full legal arguments and evidence rather than just material facts. It includes mandatory sections for third-party funding disclosures and specific paragraph-by-paragraph replies to allegations.
When should you use it?
Use this template when the arbitral tribunal or SIAC Rules require a full Statement of Defence in memorial format. Use the SIAC Pleading archetype instead if the proceedings only require a statement of material facts without full evidence and legal argument.
What's inside
| Clause | Name | What it does |
|---|---|---|
| 2 | Third-Party Funding Disclosure | The Respondent must disclose the existence, identity, and contact details of any third-party funder pursuant to Rule 38.1. |
| 4 | Jurisdiction | The Respondent states whether it objects to the Tribunal's jurisdiction within the time-bar set by Rule 31.2(a). |
| 5 | General Traverse | The Respondent denies every allegation in the Statement of Claim not expressly admitted to ensure no default admissions occur. |
| 8 | Affirmative Defences | The Respondent pleads specific legal justifications and may assert a set-off as a defence under Rule 33.3(b). |
| 11 | Statement of Counterclaim | The Respondent details the facts, legal grounds, and quantum for any cross-claims pursued against the Claimant. |
| 13 | Annexure Schedule | The Respondent must attach copies of all supporting documents not previously submitted as required by Rule 33.7. |
Who it's for
- a respondent in a SIAC arbitration submitting a full memorial of evidence and legal argument
- a party needing to disclose third-party funding under SIAC Rule 38.1
- a respondent pleading a counterclaim or set-off within an existing SIAC proceeding
How long it runs and how it's signed
How long
Used once
Signed by
Representative of the Respondent
Witness
Not required
Notarisation
Not required
Also needed
file with SIAC Registrar; pay counterclaim fees if applicable
Law it's drafted under
Governed by
SIAC Rules (2025, 7th Edition)
Refers to
Rule 7.2 SIAC Rules
Required by
Rule 33.3 SIAC Rules
Refers to
Rule 38.1 SIAC Rules
Jurisdiction
Singapore
General
Document info
GitLaw document. Document created on Sun Aug 9th, 2026. Last updated on Mon Aug 10th, 2026.
This document is public
Licensed under CC BY-SA 4.0 (Attribution-ShareAlike).
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